Gift Cards, Insider Risk and Hundreds of Millions Laundered: lessons learnt

Gift Cards, Insider Risk and Hundreds of Millions Laundered: Lessons from the Wilfredo Aquino TD Bank Case

In January 2026, the U.S. Department of Justice (DOJ) announced that Wilfredo Aquino, a former TD Bank employee in New York, had pleaded guilty to conspiring to launder monetary instruments after facilitating the movement of approximately $474 million in cash deposits through TD Bank accounts in exchange for retail gift cards worth just over $11,000. [justice.gov], [todayville.com]

The case is notable not for its novelty, but for its stark illustration of how modest personal incentives, combined with weak internal controls, can expose global banks to massive criminal abuse.

It also reinforces the critical importance of insider risk management, transaction monitoring, and staff accountability in anti-money laundering (AML) frameworks.

What Happened: An Insider Facilitates a $474 Million Laundering Network.

According to DOJ court filings, Aquino served as an assistant store manager at a TD Bank branch in Midtown Manhattan between 2019 and February 2021. During that period, he abused his position to support a money laundering organisation led by Da Ying Sze, also known as “David”, enabling the network to move approximately $474 million in cash deposits through TD Bank branches in New York, New Jersey, and elsewhere. [justice.gov]

The laundering was operationally simple but highly effective:

• Large volumes of cash were deposited into TD Bank accounts
• Funds were quickly converted into official bank cheques
• Aquino repeatedly failed to identify the true conductor of the transactions
• Mandatory Currency Transaction Reports (CTRs) were filed inaccurately or misleadingly

According to prosecutors, Aquino processed approximately 1,680 official bank cheques totalling more than $92 million, most of which were backed by cash deposits exceeding the $10,000 reporting threshold. [todayville.com]

The Bribe: Thousands in Gift Cards, Not Millions in Cash

What makes the case particularly sobering is the scale mismatch between the crime (approximately $474 million in cash deposits)  and the personal benefit ($11,000.00)

In exchange for enabling the laundering scheme, Aquino received retail gift cards valued at just over $11,000, according to the DOJ. There is no evidence that he received hundreds of thousands, or even tens of thousands, of dollars in direct cash bribes. [todayville.com]

This underscores a critical AML reality:

Insider-enabled laundering does not require large bribes; it only requires weak controls, poor supervision, and a willingness to ignore red flags.

The DOJ emphasised that Aquino knew TD Bank had closed other accounts linked to the same criminal network and had been warned by colleagues that the activity appeared suspicious, yet continued to process transactions regardless. [todayville.com]

Why This Case Matters to the Wider Banking Sector

Although Aquino is an individual defendant, his conduct cannot be viewed in isolation. The case forms part of a broader enforcement action against TD Bank, which in October 2024 pleaded guilty to Bank Secrecy Act violations and agreed to pay approximately $3 billion in combined penalties, the largest AML-related fine in U.S. banking history. [cnbc.com], [thepaypers.com]

Regulators concluded that:

• Over 90% of transactions went unmonitored over several years
• Multiple criminal networks exploited TD Bank systems
• The bank failed to detect or escalate insider misconduct promptly

The Aquino case demonstrates how employee-level failures can scale into institution-wide liability, especially when oversight is weak and frontline staff are not effectively monitored.

Key AML and Governance Lessons

1. Insider Risk Is a Core AML Threat

AML programmes often focus on customers, geographies, and transaction typologies. The Aquino case reinforces the need for explicit insider risk frameworks, including staff behaviour analytics and enhanced supervision of high-risk roles. [wp.nyu.edu]

2. CTR Accuracy Matters Not Just Filing

The issue was not a failure to file CTRs, but a failure to correctly identify the true conductor of transactions, undermining law enforcement visibility and enabling network concealment. [justice.gov]

3. Small Incentives Can Enable Massive Crime

Gift cards valued at a few thousand dollars were sufficient to compromise AML controls that protect hundreds of millions of dollars in transaction flows, highlighting the need for non-cash benefit monitoring. [todayville.com]

4. Culture and Escalation Failures Are Fatal

Colleagues reportedly expressed concern internally, yet the activity continued. This points to cultural weaknesses where warning signs are raised but not acted upon, a theme echoed by regulators in the TD Bank settlement. [wp.nyu.edu]

Conclusion: A Reminder That AML Fails Quietly Until It Doesn’t

The Wilfredo Aquino case is a powerful reminder that money laundering rarely begins with complex technology or sophisticated evasion. Instead, it often starts with human weakness inside trusted institutions, small compromises, and a tolerance for “looking the other way.”

For banks, fiduciaries, and regulated firms, the lesson is clear:

• AML programmes must treat employees not just as gatekeepers, but also as potential risk vectors.
• Robust monitoring, strong escalation culture, and meaningful accountability are not optional; they are essential safeguards against becoming the following enforcement headline.

Sources

• U.S. Department of Justice – TD Bank Insider Pleads Guilty to Facilitating Money Laundering (Jan 6, 2026) [justice.gov]
• Todayville – Former TD Assistant Manager Admits Role in $474 Million Laundering Scheme [todayville.com]
• CNBC – TD Bank Pleads Guilty, Will Pay $3 Billion in Fines [cnbc.com]
• The Paypers – TD Bank agrees to pay USD 3 billion in money laundering settlement [thepaypers.com]